In re: High-Tech Employee Antitrust Litigation

Filing 746

REDACTION to Declaration of Lisa J. Cisneros in Support of Plaintiffs' Supplemental Motion for Class Certification [ECF No. 418-2] by Daniel Stover, Siddharth Hariharan, Michael Devine, Mark Fichtner. (Attachments: #1 Exhibit 119, #2 Exhibit 175, #3 Exhibit 186, #4 Exhibit 192, #5 Exhibit 199, #6 Exhibit 202, #7 Exhibit 216 [Redacted], #8 Exhibit 223, #9 Exhibit 250, #10 Exhibit 295, #11 Exhibit 331, #12 Exhibit 369, #13 Exhibit 458, #14 Exhibit 557, #15 Exhibit 563, #16 Exhibit 597, #17 Exhibit 648, #18 Exhibit 650, #19 Exhibit 653, #20 Exhibit 711 part 1, #21 Exhibit 711 part 2, #22 Exhibit 711 part 3, #23 Exhibit 711 part 4, #24 Exhibit 711 part 5, #25 Exhibit 716, #26 Exhibit 872, #27 Exhibit 959, #28 Exhibit 1305)(Cisneros, Lisa) (Filed on 3/21/2014) Modified on 3/24/2014 linking entry to document #418(dhmS, COURT STAFF).

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page1 of 18

1
2
3
4
5
6

Richard M. Heimann (State Bar No. 63607)
Kelly M. Dermody (State Bar No. 171716)
Eric B. Fastiff (State Bar No. 182260)
Brendan Glackin (State Bar No. 199643)
Dean Harvey (State Bar No. 250298)
Anne B. Shaver (State Bar No. 255928)
Lisa J. Cisneros (State Bar No. 251473)
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, California 94111-3339
Telephone: [phone]
Facsimile: 415.956.1008

7
8
9
10
11

Joseph R. Saveri (State Bar No. 130064)
Lisa J. Leebove (State Bar No. 186705)
James D. Dallal (State Bar No. 277826)
JOSEPH SAVERI LAW FIRM
255 California, Suite 450
San Francisco, California 94111
Telephone: [phone]
Facsimile: 415.500.6803

12
Lead Counsel for Plaintiff Class
13
14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16

SAN JOSE DIVISION

17
18
19
20

IN RE: HIGH-TECH EMPLOYEE
ANTITRUST LITIGATION
THIS DOCUMENT RELATES TO:
All Actions

21
22

Master Docket No. 11-CV-2509-LHK
DECLARATION OF LISA J. CISNEROS
IN SUPPORT OF PLAINTIFFS’ NOTICE
OF SUPPLEMENTAL MOTION AND
SUPPLEMENTAL MOTION FOR CLASS
CERTIFICATION, AND MEMORANDUM
OF LAW IN SUPPORT________
Date:
Time:
Courtroom:
Judge:

23
24

August 8, 2013
1:30 pm
8, 4th Floor
Honorable Lucy H. Koh

25
26

I, Lisa J. Cisneros, declare:
1.

27
28

I am an associate in the law firm of Lieff, Cabraser, Heimann & Bernstein, LLP, a

member of the State Bar of California, and am admitted to practice before the United States
1095912.3

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page2 of 18

1

District Court for the Northern District of California. I am one of the counsel for the Plaintiffs in

2

this action. I make this declaration based on my own personal knowledge. If called upon to

3

testify, I could and would testify competently to the truth of the matters stated herein.

4

I.

Deposition Testimony

5

A.

Adobe

6

2.

Attached hereto as Exhibit A is a true and correct copy of the excerpts for the

7

March 15, 2013 deposition of Bruce Chizen, former Chief Executive Officer.

8
9

3.

Attached hereto as Exhibit B is a true and correct copy of the excerpts for the

March 1, 2013 deposition of Digby Horner, Senior Vice President of Engineering.

10

4.

Attached hereto as Exhibit C is a true and correct copy of the excerpts for the

11

March 28, 2013 deposition of Rosemary Arriada-Keiper, former Manager of Global

12

Compensation.

13
14

5.

August 21, 2012 deposition of Donna Morris, Senior Vice President Global Human Resources.

15
16

6.

7.

Attached hereto as Exhibit F is a true and correct copy of the excerpts for the April

5, 2013 deposition Debbie Streeter, Vice President, Total Rewards.

19
20

Attached hereto as Exhibit E is a true and correct copy of the excerpts for the

February 28, 2013 deposition of Shantanu Narayen, Chief Executive Officer.

17
18

Attached hereto as Exhibit D is a true and correct copy of the excerpts for the

8.

Attached hereto as Exhibit G is a true and correct copy of the excerpts for the

October 5, 2012 deposition of Jeffrey Vijungco, Vice President Worldwide Talent Acquisition.

21

B.

Apple

22

9.

Attached hereto as Exhibit H is a true and correct copy of the excerpts for the

23

March 5, 2013 deposition of David Alvarez, Recruiting Manager and former Research Manager.

24
25

10.

March 1, 2013 deposition of Darrin Baja, former Recruiting Manager.

26
27

Attached hereto as Exhibit I is a true and correct copy of the excerpts for the

11.

Attached hereto as Exhibit J is a true and correct copy of the excerpts for the

March 7, 2013 deposition of Richard Bechtel, Director of Executive Recruiting.

28
1095912.3

-2-

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page3 of 18

1

12.

Attached hereto as Exhibit K is a true and correct copy of the excerpts for the

2

August 23, 2012 deposition of Mark Bentley, former Director of Executive Recruiting and

3

Interim Human Resources Director.

4
5

13.

February 26, 2013 deposition of Patrick Burke, former Technical Recruiter and Staffing Manager.

6
7

14.

10

Attached hereto as Exhibit M is a true and correct copy of the excerpts for the

March 15, 2013 deposition of Steven Burmeister, Senior Director of Compensation.

8
9

Attached hereto as Exhibit L is a true and correct copy of the excerpts for the

15.

Attached hereto as Exhibit N is a true and correct copy of the excerpts for the

March 20, 2013 deposition of Tony Fadell former Senior Vice President, Ipod Division, and
advisor to Steve Jobs.

11

16.

Attached hereto as Exhibit O is a true and correct copy of the excerpts for the

12

April 11, 2013 deposition of Bob Mansfield, Senior Vice President of Technologies and former

13

Head of Macintosh Product Design Group.

14
15

17.

Attached hereto as Exhibit P is a true and correct copy of the excerpts for the

February 27, 2013 deposition of Ron Okamoto, Vice President of Developer Relations.

16

C.

Google

17

18.

Attached hereto as Exhibit Q is a true and correct copy of the excerpts for the

18

March 27, 2013 deposition of Laszlo Bock, Senior Vice President of People Operations.

19
20

19.

Attached hereto as Exhibit R is a true and correct copy of the excerpts for the

March 19, 2013 of deposition of Sergey Brin, Co-Founder.

21

20.

Attached hereto as Exhibit S is a true and correct copy of the excerpts for the

22

January 1, 2013 deposition of Shona Brown, former Senior Vice President of Business

23

Operations.

24
25

21.

Attached hereto as Exhibit T is a true and correct copy of the excerpts for the

February 27, 2013 deposition of Alan Eustace, Senior Vice President of Engineering.

26

22.

Attached hereto as Exhibit U is a true and correct copy of the excerpts for the

27

April 3, 2013 deposition of Patrick Flynn, former Apple Executive Recruiter (2002 – 2004) and

28

Senior Staffing Manager (2004 – 2006), and former Google Senior Manager (2006 – 2008).
1095912.3

-3-

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page4 of 18

1

23.

Attached hereto as Exhibit V is a true and correct copy of the excerpts for the

2

March 13, 2013 deposition of Jonathan Rosenberg, Advisor to the Office of CEO and former

3

Senior Vice President of Product Management (2002 – 2011).

4

24.

Attached hereto as Exhibit W is a true and correct copy of the excerpts for the

5

deposition Eric Schmidt, Executive Chairman, member of the Board, and former CEO (2001-

6

2011).

7
8

25.

Attached hereto as Exhibit X is a true and correct copy of the excerpts for the

deposition Frank Wagner, Director of Compensation.

9

D.

Intel

10

26.

Attached hereto as Exhibit Y is a true and correct copy of the excerpts for the

11

November 21, 2012 deposition of Deborah Conrad, Senior Vice President of Human Resources.

12
13

27.

March 15, 2013 deposition of Randall Goodwin, Technology Development Manager.

14
15

28.

Attached hereto as Exhibit AA is a true and correct copy of the excerpts for the

March 22, 2013 deposition of Renee James, Manager of the Software and Services Group.

16
17

Attached hereto as Exhibit Z is a true and correct copy of the excerpts for the

29.

Attached hereto as Exhibit BB is a true and correct copy of the excerpts for the

March 20, 2013 deposition of Daniel McKell, Compensation and Benefits Specialist.

18

30.

Attached hereto as Exhibit CC is a true and correct copy of the excerpts for the

19

February 14, 2013 deposition of Patricia Murray, Senior Vice President and Director of

20

Leadership Strategy and former President of Human Resources.

21

31.

Attached hereto as Exhibit DD is a true and correct copy of the excerpts for the

22

January 29, 2013 deposition of Paul Otellini, Chief Executive Officer of Intel and Member of the

23

Google Board of Directors.

24

E.

Intuit

25

32.

Attached hereto as Exhibit EE is a true and correct copy of the excerpts for the

26

February 5, 2013 deposition of Bill Campbell, Chairman of Intuit Board of Directors, Co-Lead

27

Director of Apple, and “advisor” to Google.

28
1095912.3

-4-

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page5 of 18

1
2

33.

Attached hereto as Exhibit FF is a true and correct copy of the excerpts for the

March 20, 2013 deposition of Chris Galy, Director of Talent Acquisition.

3

34.

Attached hereto as Exhibit GG is a true and correct copy of the excerpts for the

4

February 2, 2013 deposition of Michael McNeal, Vice President of Talent Development, former

5

Vice President of Talent Strategy (2008 – 2010), Vice President of Talent Acquisition (2007),

6

Director of Talent Acquisition (2006) and Manager of Executive Recruitment (2003 – 2006).

7

35.

Attached hereto as Exhibit HH is a true and correct copy of the excerpts for the

8

February 14, 2013 deposition of Chuong Nguyen, Executive Recruiter and former Technical

9

Recruiter (2002 – 2006).

10
11

36.

Attached hereto as Exhibit II is a true and correct copy of the excerpts for the

March 29, 2013 deposition of Mason Stubblefield, Vice President of Human Resources.

12

37.

Attached hereto as Exhibit JJ is a true and correct copy of the excerpts for the

13

March 14, 2013 deposition of Sherry Whiteley, Senior Vice President, Chief of Human

14

Resources.

15

F.

Lucasfilm

16

38.

Attached hereto as Exhibit KK is a true and correct copy of the excerpts for the

17

February 21, 2013 deposition of Micheline Chau, former Chief Financial Officer (1991 – 2003),

18

former President and Member of the Board of Directors (2003 – 2012).

19

39.

Attached hereto as Exhibit LL is a true and correct copy of the excerpts for the

20

November 1, 2012 deposition of Sharon Coker, former Director and Senior Director of Human

21

Resources.

22

40.

Attached hereto as Exhibit MM is a true and correct copy of the excerpts for the

23

March 20, 2013 deposition of Steven Condiotti, Finance Manager for Distribution, Corporate

24

Controller, Chief Accounting Officer, Vice President of Finance and Chief Accounting Officer,

25

and VP of Finance and Chief Financial Officer.

26

41.

Attached hereto as Exhibit NN is a true and correct copy of the excerpts for the

27

March 28, 2013 deposition of George Lucas, former Chairman of the Board, Film Producer and

28

CEO (1971 – 2013).
1095912.3

-5-

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page6 of 18

1
2

42.

February 12, 2013 deposition of Michelle Maupin, Senior Manager, Compensation

3
4

Attached hereto as Exhibit OO is a true and correct copy the excerpts for the

43.

Attached hereto as Exhibit PP is a true and correct copy of the excerpts for the

February 5, 2013 deposition of Jan Van der Voort, Chief Administrative Officer.

5

G.

Pixar

6

44.

Attached hereto as Exhibit QQ is a true and correct copy of excerpts for the March

7

19, 2013 deposition of Dana Batali, Vice President of RenderMan Products.

8
9

45.

Attached hereto as Exhibit RR is a true and correct copy of the excerpts for the

January 24, 2013 deposition of Edward Catmull, President.

10

46.

Attached hereto as Exhibit SS is a true and correct copy of the excerpts for the

11

August 2, 2012 deposition of Lori McAdams, Vice President of Human Resources and

12

Administration.

13

47.

Attached hereto as Exhibit TT is a true and correct copy of excerpts for the August

14

3, 2012 deposition of James Morris, General Manager and Executive Vice President of

15

Production and former Head of Production.

16
17

48.

Attached hereto as Exhibit UU is a true and correct copy of the excerpts for the

November 3, 2012 deposition of Pamela Zissimos, Senior Recruiter.

18

49.

Attached hereto as Exhibit VV is a true and correct copy of the excerpts for the

19

March 5, 2013 deposition of Stephanie Sheehy, Manager of Human Resources Analysis.

20

II.

Deposition Exhibits

21

50.

22

LUCAS00014721.

23

51.

24

Attached hereto as Exhibit 8 is a true and correct copy of Plaintiffs’ Exhibit 8,

Attached hereto as Exhibit 119 is a true and correct copy of Plaintiffs’ Exhibit 119,

PIX00001263.

25

52.

Attached hereto as Exhibit 129 is a true and correct copy of Plaintiffs’ Exhibit 129.

26

53.

Attached hereto as Exhibit 137 is a true and correct copy of Plaintiffs’ Exhibit 137,

27

PIX00003974.

28
1095912.3

-6-

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page7 of 18

1
2

54.
PIX00004883.

3
4

55.

56.

57.

Attached hereto as Exhibit 176 is a true and correct copy of Plaintiffs’ Exhibit 176,

GOOG-HIGH TECH-00000004.

9
10

Attached hereto as Exhibit 175 is a true and correct copy of Plaintiffs’ Exhibit 175,

GOOG-HIGH-TECH-00061 040.

7
8

Attached hereto as Exhibit 173 is a true and correct copy of Plaintiffs’ Exhibit 173,

GOOG-HIGH-TECH-00193034.

5
6

Attached hereto as Exhibit 139 is a true and correct copy of Plaintiffs’ Exhibit 139,

58.

Attached hereto as Exhibit 186 is a true and correct copy of Plaintiffs’ Exhibit 186,

GOOG-HIGH TECH-00008964.

11

59.

12

231APPLE002149.

13

60.

14

Attached hereto as Exhibit 187 is a true and correct copy of Plaintiffs’ Exhibit 187,

Attached hereto as Exhibit 192 is a true and correct copy of Plaintiffs’ Exhibit 192,

GOOG-HIGH TECH-000001 07.

15

61.

16

231APPLE002140.

17

62.

18

Attached hereto as Exhibit 199 is a true and correct copy of Plaintiffs’ Exhibit 199,

Attached hereto as Exhibit 202 is a true and correct copy of Plaintiffs’ Exhibit 202,

76526DOC000011.

19

63.

20

ADOBE_000611.

21

64.

22

ADOBE_050720.

23

65.

24

231APPLE002143.

25

66.

26

231APPLE006876.

27

67.

28

231APPLE009277.
1095912.3

Attached hereto as Exhibit 210 is a true and correct copy of Plaintiffs’ Exhibit 210,

Attached hereto as Exhibit 216 is a true and correct copy of Plaintiffs’ Exhibit 216,

Attached hereto as Exhibit 223 is a true and correct copy of Plaintiffs’ Exhibit 223,

Attached hereto as Exhibit 250 is a true and correct copy of Plaintiffs’ Exhibit 250,

Attached hereto as Exhibit 268 is a true and correct copy of Plaintiffs’ Exhibit 268,

-7-

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page8 of 18

1

68.

2

231APPLE002150.

3

69.

4

231APPLE002151.

5

70.

6

Attached hereto as Exhibit 278 is a true and correct copy of Plaintiffs’ Exhibit 278,

Attached hereto as Exhibit 279 is a true and correct copy of Plaintiffs’ Exhibit 279,

Attached hereto as Exhibit 295 is a true and correct copy of Plaintiffs’ Exhibit 295,

Adobe_052076.

7

71.

8

LUCAS00061414.

9

72.

10

LUCAS00024981.

11

73.

12

LUCAS00188912.

13

74.

14

75.

76.

77.

78.

79.

80.

Attached hereto as Exhibit 397 is a true and correct copy of Plaintiffs’ Exhibit 397,

Attached hereto as Exhibit 398 is a true and correct copy of Plaintiffs’ Exhibit 398,

Attached hereto as Exhibit 399 is a true and correct copy of Plaintiffs’ Exhibit 399,

76582DOCb00004.

27
28

Attached hereto as Exhibit 393 is a true and correct copy of Plaintiffs’ Exhibit 393,

76579DOC005956.

25
26

Attached hereto as Exhibit 392 is a true and correct copy of Plaintiffs’ Exhibit 392,

76583DOC008097.

23
24

Attached hereto as Exhibit 391 is a true and correct copy of Plaintiffs’ Exhibit 391,

76583DOC002007.

21
22

Attached hereto as Exhibit 369 is a true and correct copy of Plaintiffs’ Exhibit 369,

76583DOC003888.

19
20

Attached hereto as Exhibit 360 is a true and correct copy of Plaintiffs’ Exhibit 360,

76583DOC003750.

17
18

Attached hereto as Exhibit 359 is a true and correct copy of Plaintiffs’ Exhibit 359,

PIX00003599.

15
16

Attached hereto as Exhibit 331 is a true and correct copy of Plaintiffs’ Exhibit 331,

81.

Attached hereto as Exhibit 400 is a true and correct copy of Plaintiffs’ Exhibit 400,

765825DOC001211.
1095912.3

-8-

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page9 of 18

1

82.

Attached hereto as Exhibit 416 is a true and correct copy of Plaintiffs’ Exhibit 416,

2

Declaration of Donna Morris of Adobe Systems Inc. In Support of Defendants Opposition to

3

Plaintiffs’ Motion for Class Certification.

4
5

83.
PIX00006025.

6
7

84.

85.

86.

87.

Attached hereto as Exhibit 478 is a true and correct copy of Plaintiffs’ Exhibit 478,

76616DOC012164.

14
15

Attached hereto as Exhibit 472 is a true and correct copy of Plaintiffs’ Exhibit 472,

GOOG-HIGH-TECH-00195005.

12
13

Attached hereto as Exhibit 458 is a true and correct copy of Plaintiffs’ Exhibit 458,

76616DOC007593.

10
11

Attached hereto as Exhibit 424 is a true and correct copy of Plaintiffs’ Exhibit 424,

PIX00009182.

8
9

Attached hereto as Exhibit 420 is a true and correct copy of Plaintiffs’ Exhibit 420,

88.

Attached hereto as Exhibit 557 is a true and correct copy of Plaintiffs’ Exhibit 557,

GOOG-HIGH-TECH-00293087.

16

89.

17

231APPLE073139.

18

90.

19

91.

92.

93.

Attached hereto as Exhibit 616 is a true and correct copy of Plaintiffs’ Exhibit 616,

GOOG-HIGH-TECH-00210242.

26
27

Attached hereto as Exhibit 614 is a true and correct copy of Plaintiffs’ Exhibit 614,

GOOG-HIGH-TECH-00379327.

24
25

Attached hereto as Exhibit 608 is a true and correct copy of Plaintiffs’ Exhibit 608,

GOOG-HIGH-TECH-00255349.

22
23

Attached hereto as Exhibit 597 is a true and correct copy of Plaintiffs’ Exhibit 597,

GOOG-HIGH-TECH-00056882.

20
21

Attached hereto as Exhibit 563 is a true and correct copy of Plaintiffs’ Exhibit 563,

94.

Attached hereto as Exhibit 621 is a true and correct copy of Plaintiffs’ Exhibit 621,

GOOG-HIGH-TECH-00336877.

28
1095912.3

-9-

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page10 of 18

1
2

95.

GOOG-HIGH-TECH-00265514.

3
4

96.

97.

98.

99.

100.

101.

102.

Attached hereto as Exhibit 668 is a true and correct copy of Plaintiffs’ Exhibit 668,

GOOG-HIGH-TECH-00248336.

17
18

Attached hereto as Exhibit 666 is a true and correct copy of Plaintiffs’ Exhibit 666,

GOOG-HIGH-TECH-00248307.

15
16

Attached hereto as Exhibit 661 is a true and correct copy of Plaintiffs’ Exhibit 661,

GOOG-HIGH-TECH-00059839.

13
14

Attached hereto as Exhibit 660 is a true and correct copy of Plaintiffs’ Exhibit 660,

GOOG-HIGH-TECH-00246586.

11
12

Attached hereto as Exhibit 653 is a true and correct copy of Plaintiffs’ Exhibit 653,

GOOG-HIGH-TECH-00058495.

9
10

Attached hereto as Exhibit 651 is a true and correct copy of Plaintiffs’ Exhibit 651,

GOOG-HIGH-TECH-00058868.

7
8

Attached hereto as Exhibit 650 is a true and correct copy of Plaintiffs’ Exhibit 650,

GOOG-HIGH-TECH-00265638.

5
6

Attached hereto as Exhibit 648 is a true and correct copy of Plaintiffs’ Exhibit 648,

103.

Attached hereto as Exhibit 674 is a true and correct copy of Plaintiffs’ Exhibit 674,

GOOGcHJGH-TECH-00252601

19

104.

20

LUCAS00013705.

21

105.

22

LUCAS00194841.

23

106.

Attached hereto as Exhibit 690 is a true and correct copy of Plaintiffs’ Exhibit 690,

Attached hereto as Exhibit 710 is a true and correct copy of Plaintiffs’ Exhibit 710,

Attached hereto as Exhibit 711 is a true and correct copy of Plaintiffs’ Exhibit 711,

24

Declaration of Michelle Maupin In Support of Defendants Opposition to Plaintiffs’ Motion for

25

Class Certification.

26

107.

27

LUCAS00188708.

Attached hereto as Exhibit 715 is a true and correct copy of Plaintiffs’ Exhibit 715,

28
1095912.3

- 10 -

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page11 of 18

1

108.

2

LUCAS00185312.

3

109.

4

LUCAS00201067.

5

110.

6

LUCAS00060705.

7

111.

8

LUCAS00198130.

9

112.

10

LUCAS00199904.

11

113.

12

76596DOC01701 0.

13

114.

14

115.

Attached hereto as Exhibit 728 is a true and correct copy of Plaintiffs’ Exhibit 728,

Attached hereto as Exhibit 729 is a true and correct copy of Plaintiffs’ Exhibit 729,

Attached hereto as Exhibit 730 is a true and correct copy of Plaintiffs’ Exhibit 730,

Attached hereto as Exhibit 781 is a true and correct copy of Plaintiffs’ Exhibit 781,

Attached hereto as Exhibit 872 is a true and correct copy of Plaintiffs’ Exhibit 872,

Attached hereto as Exhibit 912 is a true and correct copy of Plaintiffs’ Exhibit 912,

INTUIT_040817.

17
18

Attached hereto as Exhibit 727 is a true and correct copy of Plaintiffs’ Exhibit 727,

GOOG-HIGH-TECH-00264994.

15
16

Attached hereto as Exhibit 716 is a true and correct copy of Plaintiffs’ Exhibit 716,

116.

Attached hereto as Exhibit 914 is a true and correct copy of Plaintiffs’ Exhibit 914,

INTUIT_001614.

19

117.

20

LUCAS00061513.

21

118.

22

LUCAS00189276.

23

119.

24

LUCAS00188708.

25

120.

26

Attached hereto as Exhibit 945 is a true and correct copy of Plaintiffs’ Exhibit 945,

Attached hereto as Exhibit 959 is a true and correct copy of Plaintiffs’ Exhibit 959,

Attached hereto as Exhibit 1107 is a true and correct copy of Plaintiffs’ Exhibit

1107, INTUIT_007865.

27
28

Attached hereto as Exhibit 944 is a true and correct copy of Plaintiffs’ Exhibit 944

121.

Attached hereto as Exhibit 1130 is a true and correct copy of Plaintiffs’ Exhibit

1130, 231APPLE099371.
1095912.3

- 11 -

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page12 of 18

1
2

122.

1158, ADOBE_005661.

3
4

123.

124.

125.

126.

127.

128.

129.

130.

131.

132.

133.

134.

Attached hereto as Exhibit 1613 is a true and correct copy of Plaintiffs’ Exhibit

1613, GOOG~IGH-TECH-00473658.

27
28

Attached hereto as Exhibit 1609 is a true and correct copy of Plaintiffs’ Exhibit

1609, GOOG-HIGH-TECH-004 75237.

25
26

Attached hereto as Exhibit 1606 is a true and correct copy of Plaintiffs’ Exhibit

1606, GOOG-HIGH TECH-00036287.

23
24

Attached hereto as Exhibit 1600 is a true and correct copy of Plaintiffs’ Exhibit

1600, 2004 Google Salary Ranges.

21
22

Attached hereto as Exhibit 1376 is a true and correct copy of Plaintiffs’ Exhibit

1376, 231APPLE039426.

19
20

Attached hereto as Exhibit 1309 is a true and correct copy of Plaintiffs’ Exhibit

1309, PIX00049648.

17
18

Attached hereto as Exhibit 1308 is a true and correct copy of Plaintiffs’ Exhibit

1308, Pixar Salary Analysis.

15
16

Attached hereto as Exhibit 1306 is a true and correct copy of Plaintiffs’ Exhibit

1306, PIX00012996.

13
14

Attached hereto as Exhibit 1305 is a true and correct copy of Plaintiffs’ Exhibit

1305, PIX00049042.

11
12

Attached hereto as Exhibit 1250 is a true and correct copy of Plaintiffs’ Exhibit

1250, ADOBE_011976.

9
10

Attached hereto as Exhibit 1160 is a true and correct copy of Plaintiffs’ Exhibit

1160, ADOBE_009652.

7
8

Attached hereto as Exhibit 1159 is a true and correct copy of Plaintiffs’ Exhibit

1159, ADOBE_019278.

5
6

Attached hereto as Exhibit 1158 is a true and correct copy of Plaintiffs’ Exhibit

135.

Attached hereto as Exhibit 1618 is a true and correct copy of Plaintiffs’ Exhibit

1618, GOOG-HIGH-TECH-00474897.
1095912.3

- 12 -

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page13 of 18

1
2

136.

1625, GOOG-HIGH-TECH-00506628.

3
4

137.

138.

139.

140.

Attached hereto as Exhibit 1761 is a true and correct copy of Plaintiffs’ Exhibit

1761, INTUIT _049796.

11
12

Attached hereto as Exhibit 1760 is a true and correct copy of Plaintiffs’ Exhibit

1760, INTUIT _052803.

9
10

Attached hereto as Exhibit 1753 is a true and correct copy of Plaintiffs’ Exhibit

1753, GOOG-HIGH-TECH-00325500.

7
8

Attached hereto as Exhibit 1629 is a true and correct copy of Plaintiffs’ Exhibit

1629, GOOG-HIGH-TECH-00509662.

5
6

Attached hereto as Exhibit 1625 is a true and correct copy of Plaintiffs’ Exhibit

141.

Attached hereto as Exhibit 1854 is a true and correct copy of Plaintiffs’ Exhibit

1854, 2231APPLE100673.

13

142.

Attached hereto as Exhibit 1855 is a true and correct copy of Plaintiffs’ Exhibit

14

1855, Declaration of Steven Burmeister In Support of Defendants’ Opposition to Plaintiffs

15

Motion for Class Certification.

16
17

143.

1856, 231APPLE1 05342.

18
19

144.

145.

146.

147.

Attached hereto as Exhibit 1869 is a true and correct copy of Plaintiffs’ Exhibit

1869, GOOG-HIGH-TECH-00550725.

26
27

Attached hereto as Exhibit 1868 is a true and correct copy of Plaintiffs’ Exhibit

1868, GOOG-HIGH-TECH-00550729.

24
25

Attached hereto as Exhibit 1859 is a true and correct copy of Plaintiffs’ Exhibit

1859, 231APPLE1 05324.

22
23

Attached hereto as Exhibit 1858 is a true and correct copy of Plaintiffs’ Exhibit

1858, 231APPLE098912.

20
21

Attached hereto as Exhibit 1856 is a true and correct copy of Plaintiffs’ Exhibit

148.

Attached hereto as Exhibit 1870 is a true and correct copy of Plaintiffs’ Exhibit

1870, GOOG-HIGH-TECH-00550726.

28
1095912.3

- 13 -

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page14 of 18

1
2

149.

1871, GOOG-HIGH-TECH-00061052.

3
4

150.

151.

152.

153.

154.

155.

156.

157.

158.

159.

160.

161.

Attached hereto as Exhibit 2140 is a true and correct copy of Plaintiffs’ Exhibit

2140, INTUIT_039756.

27
28

Attached hereto as Exhibit 2135 is a true and correct copy of Plaintiffs’ Exhibit

2135, INTUIT_034255.

25
26

Attached hereto as Exhibit 2100 is a true and correct copy of Plaintiffs’ Exhibit

2100, LUCAS00217547.

23
24

Attached hereto as Exhibit 2096 is a true and correct copy of Plaintiffs’ Exhibit

2096, LUCAS00217124.

21
22

Attached hereto as Exhibit 2094 is a true and correct copy of Plaintiffs’ Exhibit

2094, LUCAS00218283.

19
20

Attached hereto as Exhibit 2002 is a true and correct copy of Plaintiffs’ Exhibit

2092, LUCAS00217253.

17
18

Attached hereto as Exhibit 2088 is a true and correct copy of Plaintiffs’ Exhibit

2088, LUCAS00218299.

15
16

Attached hereto as Exhibit 2084 is a true and correct copy of Plaintiffs’ Exhibit

2084, LUCAS00218268.

13
14

Attached hereto as Exhibit 2035 is a true and correct copy of Plaintiffs’ Exhibit

2035, 76657DOC019261.

11
12

Attached hereto as Exhibit 2033 is a true and correct copy of Plaintiffs’ Exhibit

2033, 76657DOC004599.

9
10

Attached hereto as Exhibit 2030 is a true and correct copy of Plaintiffs’ Exhibit

2030, Declaration of Danny McKell In Support Of Opposition to Class Certification.

7
8

Attached hereto as Exhibit 1872 is a true and correct copy of Plaintiffs’ Exhibit

1872, GOOG-HIGH-TECH-00550723.

5
6

Attached hereto as Exhibit 1871 is a true and correct copy of Plaintiffs’ Exhibit

162.

Attached hereto as Exhibit 2142 is a true and correct copy of Plaintiffs’ Exhibit

2142, INTUIT_039793.
1095912.3

- 14 -

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page15 of 18

1
2

163.

2422, GOOG-HIGH-TECH-00328300.

3
4

164.

Attached hereto as Exhibit 2425 is a true and correct copy of Plaintiffs’ Exhibit

2425, GOOG-HIGH TECH-00625147.

5
6

Attached hereto as Exhibit 2422 is a true and correct copy of Plaintiffs’ Exhibit

165.

Attached hereto as Exhibit 2426 is a true and correct copy of Plaintiffs’ Exhibit

2426, GOOG-HIGH-TECH-00281629.

7

166.

Attached hereto as Exhibit 2486 is a true and correct copy of Plaintiffs’ Exhibit

8

2486, Declaration of Donna Morris of Adobe Systems Inc. In Support of Defendants Opposition

9

to Plaintiffs Motion for Class Certification.

10
11

167.

2487, ADOBE_100600.

12
13

168.

169.

170.

171.

172.

173.

174.

Attached hereto as Exhibit 2744 is a true and correct copy of Plaintiffs’ Exhibit

2744, INTUIT 052826.

26
27

Attached hereto as Exhibit 2743 is a true and correct copy of Plaintiffs’ Exhibit

2743, INTUIT_041933.

24
25

Attached hereto as Exhibit 2740 is a true and correct copy of Plaintiffs’ Exhibit

2740, INTUIT _052841.

22
23

Attached hereto as Exhibit 2739 is a true and correct copy of Plaintiffs’ Exhibit

2739, INTUIT_043560.

20
21

Attached hereto as Exhibit 2738 is a true and correct copy of Plaintiffs’ Exhibit

2738, INTUIT_043557.

18
19

Attached hereto as Exhibit 2735 is a true and correct copy of Plaintiffs’ Exhibit

2735, GOOG-HIGH-TECH-00480249.

16
17

Attached hereto as Exhibit 2501 is a true and correct copy of Plaintiffs’ Exhibit

2501, ADOBE_009425.

14
15

Attached hereto as Exhibit 2487 is a true and correct copy of Plaintiffs’ Exhibit

175.

Attached hereto as Exhibit 2800 is a true and correct copy of Plaintiffs’ Exhibit

2800, ADOBE_068264.

28
1095912.3

- 15 -

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page16 of 18

1
2

I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.

3

Executed May 10, 2013, in San Francisco, California.

4
/s/ Lisa J. Cisneros
Lisa J. Cisneros

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1095912.3

- 16 -

CISNEROS DECLARATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page17 of 18

1
2
3
4
5
6

Richard M. Heimann (State Bar No. 63607)
Kelly M. Dermody (State Bar No. 171716)
Eric B. Fastiff (State Bar No. 182260)
Brendan Glackin (State Bar No. 199643)
Dean Harvey (State Bar No. 250298)
Anne B. Shaver (State Bar No. 255928)
Lisa J. Cisneros (State Bar No. 251473)
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, California 94111-3339
Telephone: [phone]
Facsimile: 415.956.1008

7
8
9
10
11

Joseph R. Saveri (State Bar No. 130064)
Lisa J. Leebove (State Bar No. 186705)
James D. Dallal (State Bar No. 277826)
JOSEPH SAVERI LAW FIRM
255 California, Suite 450
San Francisco, California 94111
Telephone: [phone]
Facsimile: 415.500.6803

12
Lead Counsel for Plaintiff Class
13
14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16

SAN JOSE DIVISION

17
18
19
20

IN RE: HIGH-TECH EMPLOYEE
ANTITRUST LITIGATION
THIS DOCUMENT RELATES TO:

Master Docket No. 11-CV-2509-LHK
MANUAL FILING NOTIFICATION
PURSUANT TO LOCAL RULE 5.1(f)

All Actions

21
22
23
24

MANUAL FILING NOTIFICATION
Regarding: Exhibits A through VV and Plaintiffs’ Exhibits attached to the Declaration of Lisa J.
Cisneros in Support of Plaintiffs’ Supplemental Motion for Class Certification.

25
26

1.

Clerk’s office. If you are a participant on this case, this filing will be served in hard-copy shortly.

27
28

This filing is in physical form only, and is being maintained in the case file in the

2.

For information on retrieving this filing directly from the Court, please see the

Court’s main website at http://www.cand.uscourts.gov under Frequently Asked Questions (FAQ).
1097431.1

MANUAL FILING NOTIFICATION
NO. 11-CV-2509-LHK

Case5:11-cv-02509-LHK Document418-2 Filed05/10/13 Page18 of 18

1
2
3

3.

This filing was not efiled for the following reason(s):

___ Voluminous Document (PDF file size larger than efiling system allowances)
___ Unable to Scan Documents
___ Physical Object (description): ____ _________________________ _________

4

___ Non Graphical/Textual Computer File (audio, video, etc.) on CD or other media

5

___ Item Under Seal

6

___ Conformance with the Judicial Conference Privacy Policy (General Order 53).
__X Other (description): _Pending Motion to Seal Filed on May 10, 2013______

7
Executed May 10, 2013, in San Francisco, California.
8
/s/ Lisa J. Cisneros
Lisa J. Cisneros

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1097431.1

-2-

MANUAL FILING NOTIFICATION
NO. 11-CV-2509-LHK